A complaint named the owner, so the owner could not run it

The situation

Kerem and Dante had known each other since university, long before either of them had a company to run. When Kerem built his actuarial consulting practice into a firm with several offices and revenue in the low eight figures, Dante came on as operations director, the person who handled whatever Kerem was too busy or too close to the situation to handle himself. It was, for years, a workable arrangement. Grace fit into the firm differently. She was not an employee; she was a chiropractor who came in one day a week under contract to run an on-site wellness clinic for staff who spent long hours at a desk under deadline pressure, a benefit Kerem was proud of and mentioned in recruiting pitches. Over two years, Grace had treated most of the senior staff, including Kerem, and the relationship between all three had been, by every account, an easy one.

That was the backdrop the complaint landed against. Grace filed a formal written complaint alleging a pattern of unwelcome comments and conduct from Kerem over several months, the kind of complaint the firm's workplace violence and harassment policy was, on paper, built to receive and process. The trouble was immediate and structural. The policy named the firm's operations lead, Dante, as the person responsible for receiving and investigating complaints. Dante could not investigate his own close friend and business partner, not credibly, and he knew it the moment he read the complaint.

This was not the firm's first brush with this exact problem. Two years earlier, after a much smaller dispute between two junior staff members that Kerem had personally waded into and mishandled, we had been retained to review the firm's policies and had recommended, specifically, that Kerem name someone other than himself or Dante as the designated recipient for complaints, given how closely tied the two of them were, and that both complete formal training on how the investigation process was actually supposed to run. Kerem had approved the updated policy document. He had not implemented the training, and he had not changed the named contact. The policy existed. It had never been tested.

Now it was being tested, with the owner himself as the subject of the complaint, a contractor rather than an employee bringing it, and the one person on staff positioned to run the process disqualified by his own friendship with the man being accused.

The problem

Ontario's occupational health and safety framework requires employers to maintain a workplace violence and harassment policy and, critically, a program for putting that policy into action: a designated way to receive complaints, a process for investigating them that is appropriate in the circumstances, and a way of communicating the outcome to the people involved. A policy sitting in a binder satisfies none of that if the process behind it cannot actually function when a real complaint arrives. Kerem's firm had the binder. It did not have a working process, because the one person named in it to run that process was the owner's closest friend.

There was a second layer to the problem that made it more delicate rather than less. Grace was not an employee. She was an independent contractor providing services on-site, and while Ontario's workplace harassment protections extend broadly to cover the workplace itself rather than strictly employment status, the firm had never actually turned its mind to how its policy applied to a contractor rather than staff. Getting that wrong, either by wrongly excluding her complaint from the process or by mishandling it in a way that looked like it was being minimized because she was not technically an employee, carried its own risk independent of whatever the investigation itself found.

The core problem, though, was independence. Any investigation Dante ran, however carefully, would be vulnerable to the argument that it could not be trusted, given his relationship with Kerem. Any investigation Kerem tried to direct or influence, even at arm's length, carried the same flaw doubled. The firm needed someone with no relationship to any of the three people involved, no financial stake in the outcome, and enough investigative experience to run a fair, thorough process that both Grace and Kerem, whatever the findings turned out to be, could each accept as legitimate.

There was also the matter of Kerem himself, a repeat client who had been told plainly two years earlier what the gap in his process was and had not closed it. That history did not change what needed to happen now, but it meant the rebuild had to be more than a one-time fix for this complaint. It had to be a process the firm would actually use the next time, whether or not Kerem was personally involved.

What we did

1. Confirmed Dante's conflict immediately and removed him from any role in receiving or handling the complaint, formally documenting the reason in writing so there could be no later suggestion the firm had tried to keep the process in-house despite an obvious and foreseeable conflict of interest sitting at its center. Acting on this within the first day mattered because any delay would have let Dante remain the record-holder for a complaint he could not credibly investigate, a gap either side could later point to as evidence the firm had not taken the conflict seriously.
2. Retained an independent, outside workplace investigator with no prior relationship to the firm, Kerem, Dante, or Grace, selected specifically for experience handling complaints naming a business owner, since that fact pattern requires a level of independence an internal process, however well-intentioned, cannot credibly provide to either side. The investigator's mandate letter set out the scope of the inquiry and confirmed her findings would be final and binding on the firm, which gave both Grace and Kerem a process neither could dismiss afterward as a formality.
3. Clarified the policy's application to Grace's status as a contractor in writing before the investigation began, confirming the firm's workplace harassment process applied to her complaint on the same footing as it would to an employee, closing off any later argument that her contractor status had shaped how seriously the complaint was taken by anyone involved. This step also protected the firm itself, since treating a contractor's complaint as lesser than an employee's would have created a second, separate exposure regardless of what the investigation ultimately found.
4. Advised Kerem to step back entirely from any operational involvement in the investigation, including no informal conversations with staff about it, which required an uncomfortable but necessary conversation about how a business owner's ordinary instinct to manage a problem directly can itself compromise a process meant to be independent of him specifically. We gave Kerem a short, specific list of what stepping back actually meant in practice, since a vague instruction to stay out of it was not going to be enough for someone used to running every part of his own firm.
5. Coordinated logistics for the investigator, including confidential interview scheduling for Grace, Kerem, and several staff witnesses, and a secure channel for the investigator's findings that kept the process insulated from day-to-day firm operations and office gossip while it was underway. Handling scheduling ourselves rather than through Dante's office meant witnesses could be interviewed without word of who had been called circulating through the firm before the investigation had even finished gathering facts.
6. Reviewed the investigator's draft findings for procedural soundness before they were finalized, checking that every person interviewed had been given a fair opportunity to respond and that the reasoning connecting the evidence to the conclusions was sound enough to withstand scrutiny from either side afterward. This review did not touch the substance of what the investigator concluded, only whether the process behind it could stand up to a challenge from a party unhappy with the result.
7. Rebuilt the firm's policy and training program once the investigation concluded, this time naming an external ombudsperson rather than internal staff as the designated recipient for any complaint involving Kerem, Dante, or another senior leader, and scheduling mandatory annual training for the firm's full management team rather than leaving it, as before, as a document nobody ever revisited. Naming a person entirely outside the firm's own reporting lines closed the exact gap that had made this complaint so hard to process in the first place.

The outcome

The independent investigation concluded after a several-week process, finding that specific comments Kerem had made, while not rising to the most serious end of the conduct alleged, had crossed a real line and warranted a formal response, alongside a clear finding that other elements of the complaint were not substantiated. Kerem accepted the findings without dispute, completed a remedial coaching program the investigator recommended, and issued a direct acknowledgment to Grace, who continued her contract with the firm afterward on the same terms as before.

What made the process a genuine win was not the specific findings, which were mixed rather than a clean vindication for either side, but that both Grace and Kerem accepted them as fair, and the firm's other staff, several of whom had been interviewed as witnesses, saw a real, independent process play out rather than a friend investigating a friend. That credibility outcome was the one that mattered most for a firm of this size, where staff trust in how complaints get handled affects retention far beyond any single incident.

The firm has since used its rebuilt policy, with the external ombudsperson and mandatory training now actually in place, for two smaller matters that arose in the following year, both handled without needing to reconstruct a process from scratch under pressure the way this one had to be. Kerem, notably, did not treat the second round of advice the way he had treated the first. The policy that had sat unused for two years is now, by his own account, the piece of the firm's governance he checks most carefully.

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